Description of Bilot Oyj’s Marketing register

• Controller

Name: Bilot Oyj (“Bilot”)

Contact information:
Bilot Oyj, Porkkalankatu 22 A, 00180 Helsinki, Finland
Phone: +358 10 5484800

• Contact person

Name: Kristiina Sarén

Contact information:
+358 40 8222796
kristiina.saren@bilot.fi

• Data protection officer

Name: Jens Krogell

Contact information:
+358 40 742 6062
jens.krogell@bilot.fi

• Name of the register

Marketing Register

• The purpose of the processing of the personal data and the legal basis for the processing

Personal data is processed for the purpose of customer relationship management, providing marketing information and handling other matters related to the management of Bilot websites and the services and materials provided by Bilot.
The legal basis for the processing is Bilot’s legitimate interest (direct marketing) or the consent given by data subject.

• Content of the register

General contact and personal information, such as name, address, email, phone, organization, web and email traffic data and other information required to manage Bilot’s marketing communication.

• The period for which the personal data will be stored/the criteria used to determine that period

All data will be reviewed, refreshed and if needed – deleted annually. The personal data will be stored as long as the data subject belongs to the target group of marketing which is based on his or her position and the data subject has not prohibited Bilot to use his or her personal data to marketing purposes.

• Regular sources of information

Data is either volunteered to marketing purposes directly from the data subject or gathered from other companies or from public sources such as social media or company websites. Data subjects can at any time prohibit Bilot from using their personal data for marketing purposes.

• Regular destinations of disclosed data

The data may be transferred within the Bilot group of companies. Third party service providers may be used to process personal data on behalf of the Bilot group of companies.

• Whether data are transferred to countries outside the EU or the EEA

Transfers outside the EU or the EEA are possible in third party services but conducted in accordance with the Finnish Data Protection Act (523/1999) and the General Data Protection Regulation (2016/679).

• The principles how the data files are secured

Bilot ensures that adequate protection is in place to prevent unauthorized access to personal data in accordance with Bilot’s data security policy. Access to digitally stored data through software and hardware is restricted to dedicated personnel and protected by user rights, passwords and encryption where applicable. All personnel accessing the data is bound to confidentiality obligations.

• The data subject’s right to prohibit the processing of personal data to direct marketing purposes

The data subject has a right to withdraw his or her consent and prohibit Bilot to process his or her personal data for purposes of direct advertising and other direct marketing. Bilot offers an easy way to opt-out from using data subject’s personal data for such purposes in every email we send. The data subject can also contact Bilot in accordance with section 14 of this description of the file.

• Other rights of the data subject

1. The data subject’s right of access to the data
   
   The data subject has a right to obtain from Bilot whether or not personal data concerning him or her is being processed and information concerning such data. Bilot shall provide a copy of data subject’s personal data without any charge but for any further copies Bilot may charge a reasonable fee.
   
   
2. The data subject’s right to demand rectification
   
   The data subject has a right to obtain Bilot without undue delay the rectification of inaccurate personal data and taking into account the purposes of the processing a right to have incomplete personal data completed.
   
   
3. The data subject’s right to demand erasing of data or a restriction on processing the data
   
   The data subject has a right to obtain Bilot without undue delay the erasure of personal data concerning him or her for example in a case 1) where the personal data are no longer necessary in relation to the purposes for which they were collected or processed 2) the data subject withdraws consent on which the processing is based on and where there is no other legal ground for processing. The data subject may also obtain from Bilot restriction of processing, when for example Bilot is verifying the accuracy of the personal data said to be inaccurate.
   
   
4. The data subject’s right to data portability
   
   The data subject has a right to access the data and to transfer the data to another controller in case the data subject has provided the data to Bilot based on his or her consent and the processing is carried out by automated means.
   
   
5. The data subject’s right to make a complaint to the supervising authorities
   
   If the data subject considers that Bilot has not followed applicable data protection regulations, it can lodge a complaint to the supervising authorities.
   
   
6. Consent
   
   Where Bilot processes the personal data on the basis of the data subject’s consent, the data subject can at any time withdraw its consent.
   

• Contact

If the data subject wants to review the accuracy related to his or her personal data or otherwise to use his or her above mentioned rights, the email address to contact is datasecurity@bilot.fi . The request should be sent from the email given to Bilot. The request can also be made in writing and be sent to Bilot to the address Porkkalankatu 22 A, 00180, Helsinki, Finland. The request must be personally signed or otherwise comparably verified and in the message there must be defined which right the request refers to.  Bilot can request the data subject to further define their request.